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On April 20, 2004, respondent’s Appeals Office sent
petitioner a copy of Form 4340, Certificate of Assessments,
Payments and Other Specified Matters, for 2000 and told him that:
(a) Petitioner could not challenge his underlying tax liability
as determined by respondent because he had previously been given
the opportunity to dispute it, and (b) the Appeals Office does
not consider challenges based on constitutional, religious,
political, or moral grounds.
On June 2, 2004, Settlement Officer Joe M. Breazeale
(Breazeale) reviewed respondent’s administrative file and
telephoned petitioner. Petitioner requested a face-to-face
hearing. Breazeale told petitioner that he would not offer him a
face-to-face hearing unless he had nonfrivolous issues to
discuss. In a telephone call on June 10, 2004, Breazeale told
petitioner that petitioner could not challenge his underlying tax
liability because he had received the notice of deficiency and
failed to petition the Tax Court. Breazeale and petitioner also
discussed the process for an offer-in-compromise. Petitioner
told Breazeale he would call him on June 18, 2004, and tell him
how he wanted to proceed. Petitioner did not contact Breazeale
on June 18, 2004, or thereafter.
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Last modified: May 25, 2011